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Global Magnitsky (Human Rights)

UN Sanctions 

There is no UN sanction regime targeting human rights violations. 

EU Sanctions 

The EU human rights sanction regime is based on "COUNCIL REGULATION (EU) 2020/1998 of 7 December 2020 concerning restrictive measures against serious human rights violations and abuses."


It is a thematic sanctions regime with the following restrictive measures in place:

  • Financial sanctions (asset freeze) 

  • Travel bans

U.S. Sanctions 

Similar to Magnitsky's sanction this sanction program is a list-based and conduct-based program. In fact, one can say the Global Magnitsky program is similar to the Magnitsky program with designation criteria not limited to Russia and the events surrounding the killing of Sergei Magnitsky. 

In particular, following the passage of the Global Magnitsky Human Rights Accountability Act in December 2016 which invited the President to impose certain sanctions, on December 20, 2017, by issuing E.O. 13818, the President determined that serious human rights abuse and corruption around the world constitute an unusual and extraordinary threat to the national security, foreign policy, and economy of the United States. And accordingly, he established a new sanctions regime against corruption and human rights abuses around the world. 

This sanction program consists of financial sanctions (asset freeze) and travel bans for those listed under it. Depending on how one defines secondary sanctions, this program might be considered among those with secondary sanctions. The argument for that would be Section 1 (a)(iii)(A)(2) which provides the authority for the designation of any person who has materially assisted, sponsored, or provided financial, material, or technological support for, or goods or services to or in support of any person whose property and interests in property are blocked pursuant to this order. 

Those listed pursuant to this program have the tag of [GLOMAG] next to their name on the SDN list. 

The relevant regulations for this program are codified under 31 C.F.R.§583

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